Case Summary (G.R. No. 164940)
Key Dates
- March 17, 1989: Rush telegrams sent
- May 2, 1989: Initial NTC hearing
- June 15, 1989: NTC proceeds with evidence despite RCPI’s motion to defer
- October 3, 1989: NTC denies RCPI’s motion to dismiss
- November 27, 1989: NTC imposes P1,000 fine
- November 6, 1992: Supreme Court decision
Applicable Law
- Commonwealth Act No. 146 (Public Service Act), §§ 13, 19(a), 21
- Executive Order No. 546 (July 23, 1979)
- 1987 Philippine Constitution
Facts
On March 17, 1989, Dr. Jimena Alegre used RCPI’s rush-telegram service to inform relatives in Bohol and Ilocos Norte of a death. The telegrams arrived days late. Juan Alegre filed a complaint with the NTC, seeking punitive sanctions for deficient service.
Administrative Proceedings Before the NTC
- Alegre’s letter‐complaint prompted the NTC to require RCPI’s answer and to set hearings beginning May 2, 1989.
- RCPI moved to dismiss, arguing (a) Alegre was not the real party in interest; (b) the NTC lacked jurisdiction; and (c) continued hearings violated due process. It also sought deferment of hearings pending resolution of its motion.
- On June 15, 1989, the NTC proceeded despite RCPI’s requests. On October 3, 1989, it denied RCPI’s motion to dismiss, holding Alegre had a legal interest as husband of the telegram sender, and that the NTC’s supervisory power over public communication utilities conferred jurisdiction.
- RCPI was duly notified but did not appear at resumed hearings.
NTC Decision
On November 27, 1989, the NTC found RCPI administratively liable for “deficient and inadequate service” under C.A. 146, § 19(a), and imposed a fine of P200 per day of delay, totaling P1,000. A motion for reconsideration was denied.
Petition for Review
RCPI invoked C.A. 146, § 19(a), arguing that the Public Service Commission (NTC’s predecessor) was limited to fixing rates and could not impose fines for service deficiencies. RCPI relied on prior decisions (RCPI v. Santiago, Jaugan, Board of Communications) holding that without express statutory grant, regulatory agencies lack power to fine for negligent service.
Supreme Court Analysis
- The NTC’s jurisdiction derives from C.A. 146 and E.O. 546. While E.O. 546 broadly authorizes supervision and regulation of telecommunications, it does not expressly grant power to impose fines for delayed service.
- Jurisdiction of administrative agencies is limited to powers expressly conferred or necessarily implied by statute.
- Prior jurisprudence (Globe Wireless Ltd. v. Public Service Commission) confirms that absent an explicit grant to fine for servic
Case Syllabus (G.R. No. 164940)
Facts
- On March 17, 1989 at 9:00 a.m., Dr. Jimena Alegre sent two identical rush telegrams via RCPI’s facilities in Taft Avenue, Manila, bearing the message “MANONG POLING DIED INTERMENT TUESDAY.”
- One telegram was addressed to private respondent’s sister and brother-in-law in Valencia, Bohol; the other to a sister-in-law in Espiritu, Ilocos Norte.
- Neither telegram reached its destination on the dates expected by the senders.
Administrative Complaint Before the NTC
- Private respondent Juan A. Alegre filed a letter-complaint with the National Telecommunications Commission (NTC) for poor service, requesting punitive sanctions against RCPI.
- NTC directed RCPI to file its answer and initially set the hearing for May 2, 1989; the hearing was reset twice.
- RCPI moved to dismiss on three grounds: (a) Alegre was not the real party in interest; (b) NTC lacked jurisdiction; and (c) proceeding violated due process. RCPI also sought deferment of hearings pending resolution of the motion.
NTC’s Proceedings and Penalty Imposed
- On June 15, 1989, NTC proceeded with hearings and received evidence from private respondent.
- On October 3, 1989, NTC denied RCPI’s motion to dismiss, ruling that Alegre had legal interest as the sender’s husband and that NTC’s jurisdiction over public communication utilities derived from law.
- RCPI failed to appear at subsequent hearings despite due notice.
- On November 27, 1989, NTC found RCPI administratively liable under Section 19(a) of Commonwealth Act No. 146 for deficient service and imposed an aggregate fine of ₱1,000:
- ₱600 for a three-day delay in Vale